Conflicts of Interest

The ICB is responsible for the stewardship of significant public resources when making decisions about the commissioning of health and social care services. In order to ensure and be able to evidence that these decisions secure the best possible services for the population it serves, the ICB must demonstrate accountability to relevant stakeholders, particularly the public, and probity and transparency in the decision-making process.

A key element of this assurance involves management of conflicts of interest with respect to any decisions made. The ICB manages conflicts of interest as part of its day-to-day activities. Effective handling of such conflicts is crucial for the maintenance of public trust in the commissioning system. Importantly, it also serves to give confidence to patients, providers, Parliament and tax payers that the ICB’s commissioning decisions are robust, fair, transparent and offer value for money.

This policy sets out clear and robust procedures on how the ICB manages conflicts of interest.

Mrs Julie Pomeroy, Non-Executive Member is the ICB Conflicts of Interest Guardian. The Conflicts of Interest Guardian is responsible for:

  • being a safe point of contact for employees or workers of the ICB to raise any concerns in relation to the policy
  • acting as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns regarding conflicts of interest
  • providing support, independent advice and judgment on non-publication of conflicts and minimising risks
  • providing advice on minimising the risk of conflicts of interest.

Mrs Julie Pomeroy can be contacted via email

Declaration of interests register

In complying with the NHS England guidance on Managing Conflicts of Interest it is a requirement that the ICB maintains and publishes a register of interests and gifts, hospitality and procurement. This is made available on the ICB website and shared at the Audit Committee meetings. 

All the aforementioned registers are maintained by the ICB’s Corporate Admin Team – please contact the ICB’s Board Sec or Deputy Board Sec for further information – Jules Ellis-Fenwick or Sarah Bates at or